1

SAMPLE FORM 13
DONATION MORTIS CAUSA

DEED OF DONATION

KNOW ALL MEN BY THESE PRESENTS:

This Deed of Donation made and executed in ____________Philippines

by ________________ of legal age, single/married to ________________,
Filipino citizen ad with residence and postal address at _________________,
and with residence and postal address at __________________ hereinafter
called the DONEE.

WITNESSETH:

That the Donor is the absolute owner of that certain real property
situated at ___________ and more particularly described in
Original/Transfer Certificate Title No. ______ of the Land Registry of
_________ as follows:

(Description of Property)

That for and in consideration of the love and affection which the Donor
has for the Donee, said Donor by these presents do hereby CEDES,
TRANSFERS and CONVEYS unto said Donee the real property above
described, together with all the buildings and improvements existing
 2

thereon, to become effective upon the death of the Donor, but in the event
that the Donee should die before the Donor, the present donation shall be
deemed rescinded and of no further force and effect.

That the Donee does hereby accepts this donation of the above-
described real property and do hereby expresses gratitude for the kindness
and liberality of the Donor.

That the Donor hereby retains the right to rescind the right to control
and dispose at will the above-described property before his death, without
need of the consent or intervention of the Donee.

IN WITNESS WHEREOF, we have hereunto signed this deed of

donation, this __________ day of ________,___________ at
___________Philippines.

________________ ____________________
Donor Donee

ATTESTATION CLAUSE

We, the undesigned attesting witnesses, whose residences are stated

opposite our respective names, do hereby certify:

That the donor, _____________, has made known unto us the foregoing
donation mortis causa and has signed the same and every page therein in
letters on the upper part of each page, as her donation mortis causa and has
witnesses and signed the same and every page thereof, on the left margin, in
the presence of the donor and in the presence of each and all of us.
 3

___________________________ ____________________

(Name and Signature of witness) (residence)

___________________________ ____________________

(Name and Signature of witness) (residence)

___________________________ ____________________

(Name and Signature of witness) (residence)

JOINT ACKNOWLEDGMENT

Republic of the Philippines)

Province of ____________) S.S
Municipality of _________)

BEFORE ME, Notary Public for and in the City/Municipality of

____________ this _________day of ________20___, personally appeared the
following:

DONOR , ______________ with I.D No._______ issued at ___________ on

___________;

DONEE ,______________with I.D No.________ issued at ___________

on___________;

WITNESS, ___________ with I.D No._______ issued at _________ on

__________;

WITNESS, ____________ with I.D No._______ issued at

__________ on __________.
 4

All known to me as the same persons who signed the foregoing DEED OF
DONATION MORTIS CAUSA, and they acknowledged to me that they signed the
same freely and voluntarily.

IN WITNESS WHEREOF, I have hereunto set my hand and affixed my

notarial seal, (day)(year) and (place).

NOTARY PUBLIC

Doc No. __
Page No.__
Book No.__
Series of 20__.
 5

SAMPLE FORM 14

RETAINER AGREEMENT

KNOW ALL MEN BY THESE PRESENTS:

This AGREEMENT is made and entered into by and between:

PAW LOAN ASSOCIATION INC., a duly organized corporation

existing by virtue of and under laws of the Republic of the Philippines, with
office address at Quezon City, represented by its Chairman, PAW LUH,
hereinafter referred to as “PAW LUH”:

And

ATTY. KEM TSUE,, a private lawyer, with office address at Sen Gil
Puyat Ave., Makati City, hereinafter referred to as “ATTY. KEM”

WITNESSETH, THAT:

WHEREAS, PAW LU requires the services of a lawyer to provide legal

services to PAW LOAN ASSOCIATION INC.;
 6

WHEREAS, ATTY. KEM has represented that it has the requisite

professional knowledge, experience and skill to advise and assist the PAW
LUH in achieving the aforestated objectives;

NOW THEREFORE, for and in consideration of the foregoing

premises and the mutual covenants herein contained, the parties agree as
follows:

1. SCOPE OF AGREEMENT

a. EFFECTIVITY: 01 April 2023 to 31 March 2024

b. DURATION: One year, automatically renewed on annual basis.
This retainer may be terminated by either party by serving a 60-
day advance written notice upon the other prior to its
termination date.
c. RETAINER FEE: FIFTY THOUSAND PESOS (Php 50,000.00) per
month, subject to adjustment upon mutual consent as work
develops.
d. SERVICES COVERED BY THE REGULAR RETAINER FEE:
d.1 Legal counselling, consultation and rendering legal opinions,
subject to paragraph d.5 hereof;
d.2 Reviewing contracts and other legal documents with
suggestions, whenever warranted’
d.3 Assisting in any contract negotiation, conference or business
transaction, subject to paragraph d.5 hereof;
d.4 Providing legal information and upon request, copies of new
laws, rules and regulations, and other documents with
comments and/or instructions, if necessary, whenever any such
information, law, rule, regulation or document may significantly
affect the business; and
 7

d.5 Other services which a lawyer customarily renders for a

client in the ordinary course of the association’s business.

e. SERVICES NOT CONVERED BY THE REGULAR RETAINER

FEE, THUS SUBJECT TO SEPARATE BILLING:
e.1 Court litigations, quasi-judicial cases, administrative
investigations and similar proceedings;
e.2 Major contract preparations involving extended negotiations,
and any official representation in your behalf with any
government office or entity concerning any official transaction in
which the Association is interested;
e.3 Written and exhaustive opinions; and
e.4 Documentation and/or notarization of contracts and
compliance with legal requirements of government agencies.

2. RELATIONSHIP OF THE PARTIES

It is agreed that PAW LUH and ATTY. KEM are doing business
on their own account and that the Agreement does not establish any
employer-employee relationship.

3. CONFIDENTIALITY

ATTY. KEM shall keep confidential and shall not, unless

authorized in writing, directly or indirectly, use, divulge, disclose
or communicate to any person, firm or company any secret and
confidential information about PAW LUH which shall come to her
knowledge during its engagement.
 8

The term “secret and confidential information: extends to all

knowledge and information relating to information acquired
during and relative to her consultancy as well as business activities,
operations, organizations, finances and dealings of and concerning
PAW LUH.

4. GENERAL PROVISION

The Agreement is personal in nature and may not assigned by

either party without the prior written consent of PAW LUH and
ATTY. KEM.

IN WITNESS WHEREOF, the parties have hereunto affixed their

signature this _______day of __________, __________, Quezon City.

PAW LOAN ASSOCIATION INC., ATTY. KEM TSUE

By: PAW LUH

Chairman and President

Signed in the presence of:

 9

____________________ _____________________

ACKNOWLEDGMENT

REPUBLIC OF THE PHILIPPINES)

City of ____________________) s.s

BEFORE ME, a Notary Public for and in _______________, this

day____________ of 2023, personally appeared the following
parties with their respective Competent Evidence of Identity, to
wit:

PAW LUH ID NUMBER: __________

ATTY. KEM TSUE ID NUMBER: ___________

Known to me and to me to be the same persons who executed

the foregoing instrument and acknowledged to me that the same
is their free and voluntary act and deed of the
corporation/institution they respectfully represent.

The foregoing instrument relates to Retainer Agreement has

been signed in the left and margin of the page thereof of the
parties and their instrumental witnesses and sealed with my
notarial seal.
 10

IN TESTIMONY WHEREOF, I have hereunto set my hand and

affixed my notarial seal on the date and at the place first above-
written.

NOTARY PUBLIC

Doc No.___;
Page No.__;
Book No.__;
Series of 2023.
 11

SAMPLE FORM 15
NOTARIAL WILL

Republic of the Philippines)

City of Pasay ) S.S

LAST WILL AND TESTAMENT

KNOW ALL MEN BY THESE PRESENTS:

I, MARIELLE A. SANTOS, of legal age, single, Filipino, a resident of

Unit 24, Jazz Residences, Pasay City, Philippines, being of sound mind and
disposing mind and memory, and not acting under influence, violence,
fraud of intimidation of whatever kind, do by these presents declare this to
be my Last Will and Testament which I have caused to be written in
English, the language which is known to me.
I hereby declare that:

1. The following are my parents with their addresses:

MARY A. SANTOS 675 Bangkal St. Pasay City, Philippines

 12

LUCIO R. SANTOS 675 Bangkal St. Pasay City, Philippines

2. I give and bequeath to my parents, MARY A. SANTOS and LUCIO R.

SANTOS, in equal shares, the following properties, real and personal,
whatsoever and wheresoever located:

a. A PARCEL OF LAND (Lot 1, Blk 2 of consolidation subdivision

plan (LRC) Pcs-13265, being a portion of the consolidation of Lots
xx situated in the Bo. Of San Mateo, City of Pasay, of Luzon,
Bounded xx containing an area of 280 square meters more or less:
b. 1P PIECES OF SILVER JEWELY and 6 PIECES OF GOLD
JEWELRY.

3. I designate MAURICIO A. SANTOS as the sole executor of my Last

Will and Testament, and in his default or incapacity to act, LEO LEE.

IN WITNESS WHEREOF, I have hereunto set my hand this 5th day of

July, 2018 in the City of Pasay, Philippines.

MARIELLE SANTOS
Testator

ATTESTATION CLAUSE

We, the undersigned attesting witness, whose residences are

stated opposite our respective names, do hereby certify: That the
testator, MARIELLE A. SANTOS, published unto us the foregoing
 13

will consisting of 3 pages numbered correlatively in letters on the

upper part of each page of her Last Will and Testament and has
signed the same on each and every page thereof on the left margin, in
our presence, and we, in turn, at her request have witnessed and
signed the same on each and every page thereof, on the left margin,
in the presence of the testate and in the presence of each and all of us.

LEAN B. REYES 47 Palm Drive, Pasay City

HANNE N. LOPEZ 89 Seaside Drive, Pasay City
DULCET U. RAMOS 58 Olive Drive, Pasay City

JOINT ACKNOWLEDGMENT

BEFORE ME, Notary Public for and in the City of Pasay,

Philippines this 5th day of July, 2018, personally appeared:

MARIELLE A. SANTOS, with Valid Identification Document Voter’s

ID issued by COMELEC on June 16, 2015 at Pasay City, Philippines.

LEAN B. REYES with with Valid Identification Document Voter’s ID

issued by COMELEC on January 5, 2014 at Pasay City, Philippines.

HANNE N. LOPEZ with Valid Identification Document Voter’s ID

issued by COMELEC on October 8, 2017 at Pasay City, Philippines.

DULCET U. RAMOS with Valid Identification Document Voter’s ID

issued by COMELEC on February 14, 2017 at Pasay City, Philippines.
 14

All known to me to be the same persons who signed the foregoing

WILL, the first as testator and the last three as instrumental witnesses and
they respectively acknowledged to me that they signed the same as their
own free and voluntary act and deed.

This Will consists of 3 pages, including the page in which this

acknowledgment is written, and has been signed on the left margin of each
and every page thereof by the testator and his witnesses, and sealed with
my notarial seal.

IN WITNESS WHEREOF, I have hereunto set my hand on the day,

year and at the place above written.

JOKER S. ABAD
Notary Public for Pasay City
Unit 43, Jazz Residences, Pasay City
Appointment No. 34 Until March 2020
Roll of Attorneys No. 33
PTR No. 9, March 7, 2010, Pasay City
IBP. 13141, March 7, 2010, Pasay City
Serial No. of Commission 1234

Doc No. 33
Page No. 23
Book No. 3
 15

SAMPLE FORM 16
HOLOGRAPHIC WILL

5 July 2018

1 wish to be cremated and my ashes buried under our

Talisay Tree.

I give my 1987 NISSAN SENTRA SLX to my bestfriend,

CHRIS VRAON with the bequest that he use it as his
wedding car in honor of my memory.

I give 10% of my stocks for the benefit of ANIMAL

SHELTERS/RESCUE GROUPS in my hometown.

Further, the legitime of my parents shall be taken

from the ATM taped under my computer keyboard.

Everything else, I leave for my wife ANNA.

geronimo
 16

GERONIMO B. MAGDALO

SAMPLE FORM 17
COMPLAINT FOR SUM OF MONEY

Republic of the Philippines

National Capital Judicial
Regional Trial Court
Branch 136 City of Makati

PANTALON ALVAREZ Civil Case No.13345

Plaintiff, FOR: COLLECTION FOR A SUM
OF MONEY WITH DAMAGES

-versus-

GORYA MACAPAGAL ARROYO

Defendant,

X------------------------------------------------X

COMPLAINT
 17

Plaintiff, through the undersigned counsel unto this Honorable

Court, hereby respectfully avers:
1. That plaintiff is of legal age, Filipino, married and a resident of 7F
Planters Product Bldg.109 Esteban Street, Legaspi Village, Makati
City, while the defendant is also of legal age, married, Filipino,
and a resident of 8F Planters Product Bldg.109 Esteban Street,
Legaspi Village, Makati City where summons and court processes
may be served;
2. That on February 14, 2017, the defendant borrowed from the
plaintiff a sum of money amounting to One Million Pesos
(1,000,000.00) with an agreed interest of five percent (5%) per
month as evidenced by a promissory note herein attached as
Annex “A” and form an integral part of this complaint;
3. That as shown in the attached promissory note, the indebtedness
of the defendant has become due and demandable on February 14,
2018;
4. That despite plaintiff’s repeated demands, both written and
verbal, defendant failed, neglected and refused to fulfil obligations
without just and valid grounds to the continued damage and
prejudice of plaintiff, as evidenced by Annex “B” – Demand Letters;
5. That the plaintiff in order to enforce his rights and interest, has
sought the services of a legal counsel with attorney’s fees
amounting to One Hundred Thousand Pesos (Php 100,000.00) and
an appearance fee of Two Thousand Pesos (Php 2,000.00) per
hearing as evidenced by Annex “C” Contract for Legal Services;
6. That the plaintiff has paid for litigation expenses amounting to
Twenty Thousand Pesos (Php 20,000.00) as evidenced by Annex
“D” – Official Receipt;
7. That the plaintiff has suffered moral damages at the sum
discretion of the Honorable Court;
 18

PRAYER
WHEREFORE, premises considered, it is hereby respectfully prayed
before the Honorable Court to render decision in favor of the plaintiff and
order the defendant to pay the following:

A. The sum of One Million Pesos (Php 1,000,000.00) plus interest at the
rate of five percent (5%) per month as stipulated in the promissory
note;
B. Moral damages, exemplary damages at the sum discretion of the
court;
C. Attorney’s fees amounting to One Hundred Thousand Pesos (Php
100,000.00) and an appearance fee of Two Thousand Pesos (Php
2,000,000.00) per hearing.
D. Litigation expenses amounting to Twenty Thousand Pesos (Php
20,000,000.00)

Other reliefs and remedies deemed just and equitable under the
foregoing premises are likewise prayed for.

City of Makati, July 16, 2018.

ATTY. SANTA ELENA

Counsel for Petitioner
Elena Law Office Pacific Star Building
Makati Avenue, Sen. Gil J. Puyat Ave.
Makati City, Philippines
Roll No. 54321
IBP No. 1223234/January 1, 2018/Makati City
P.T.R No. 79897/January 1, 2018/Makati City
 19

MCLE No. 122424/March 3, 2018

CTC No. 2314314/January 2, 2018/Makati City

VERIFICATION AND CERTIFICATION OF AGAINST FORUM

SHOPPING

I, PANTALON ALVAREZ, of legal age, Filipino, married and a

resident of 7F Planters Product Bldg.109 Esteban St. Village, Makati City,
after having being sworn in accordance with law, hereby depose and say:

1. That I am the plaintiff in the above-entitled case;

2. That I have caused the preparation of the above complaint and I
have read the same and understood the contents thereof;
3. That the allegations contained therein are true and correct of my
own personal knowledge and based on authentic records;
4. That I further certify that I have not theretofore commenced any
other action or proceeding or filed any claim involving the same
issues or matter in any court, tribunal or quasi-judicial agency and,
to the best of my knowledge no such action or proceeding is
pending therein; if I should thereafter learn that the same or
similar action or proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other tribunal or
quasi-judicial agency, I undertake to report such fact within five
(5) days therefrom to the court of agency wherein the original
pleading and sworn certification contemplated herein have been
filed.

PANTALON ALVAREZ
 20

Affiant

SUBSCRIBED AND SWORN to before me this 12th day of July 2018,

affiant exhibiting to me his Passport Identification No.P2324251A issued at
City of Makati on January 2, 2018, as competent evidence of his identity.

ATTY. SARA DUET

Notary Public
Until December 31, 2018
Roll No. 23345/January 1, 2018/Makati City
P.T.R No. 45346/ January 1, 2018
MCLE No. 708709/March 4, 2018
CTC No. 11879/January 2, 2018/Makati City

Doc No. 5
Page No. 12
Book No.06
Series of 2018
 21

SAMPLE FORM 18

VERIFICATION

Republic of the Philippines)

City of _______________) s.s

FERDNAN MARKUZ, after having been duly sworn in accordance

with law, hereby deposes and states that:

1. He is the plaintiff in the pleading/document entitled ___________;

2. He has caused its preparation;
3. He has read it and the allegations therein are true and correct of
his own knowledge or based on authentic records.

(sgd) FERDNAN MARKUZ

JURAT
 22

SAMPLE FORM 19

CERTIFICATION AGAINST FORUM SHOPPING

Republic of the Philippines)

City of________________) s.s

FERDNAN MARKUZ, after having been duly sworn in

accordance with law, hereby deposes and states that:

1. He is the plaintiff in the case entitled _________________;

2. He certifies that he has not commenced any action or filed
any claim involving the same issues before any other court,
tribunal or quasi-judicial agency;
3. To the best of his knowledge, there is no such pending action
or claim;
4. If he should learn that a similar action or claim has been filed
or is pending he shall report such fact within five (5) days
from the discovery to the discovery to this Honorable Court.

(sgd) FERDNAN MARKUZ

JURAT
 23

SAMPLE FORM 20

NOTICE OF HEARING
 24

SAMPLE FORM 21

PROOF OF SERVICE

Copy furnished through personal service:

Atty. INDY MAHANAP Registry Receipt

Counsel for the defendant Date:______________
(Firm Name) Post Office: ________
(Office Address)
 25

SAMPLE FORM 22

PROOF OF SERVICE THROUGH REGISTERED MAIL WITH

EXPLANATION

Copy furnished through registered mail:

ATTY. ___________________ Registry Receipt:

No.______________________ Date : _________
Counsel for ______________ Post Office: ____
Firm Name
Office Address

EXPLANATION

Pursuant to the Revised Rules of Court, service of the above

(designation of pleading or document) was effected through registered mail
because of the impracticability of personal service. The office of the
undersigned counsel is located at (office address) while that of the adverse
counsel is located at (office address) and there are no messengerial personnel
in the employ of the undersigned counsel who could effect personal
service.
 26

SAMPLE FORM 23

UNLAWFUL DETAINER COMPLAINT

Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES
FIRST JUDICIAL REGION
Branch 1
Bagui City

ELENA MAGANDA, Civil Case No._____

Plaintiff For: Unlawful Detainer

-versus-

ANNAH UTANGERA,
Defendant

COMPLAINT

Plaintiff, by counsel and unto this Honorable Court, most respectfully

avers that:

1. Plaintiff, ELENA MAGANDA, is a Filipino citizen, of legal age,

single and with residence and postal address at #2 Sanitary Camp,
Baguio City;
 27

2. Defendant, ANNAH UTANGERA, is also a Filipino citizen, of legal

age, single and with residence and postal address at #22 Kias,
Baguio City;
3. Plaintiff is the owner of an apartment located at #3 Sanitary Camp,
Baguio City, covered by Transfer Certificate Title No.50905 (Annex
“A”);
4. By virtue of a contract of lease (Annex “B”), Plaintiff leased to
Defendant the said apartment for a consideration of Php 8,000.00 a
month as rental to be paid within the first ten (10) days of each
month starting January 6, 2011;
5. From March 1, 2012 up to the present, Defendant failed to pay the
agreed rental;
6. On July 11, 2012, Plaintiff send a demand letter (“Annex C”) to
Defendant for her to vacate the apartment and pay the agreed
rentals, which was received by Defendant, as shown in the registry
return receipt (Annex “D”)
7. Despite said demand letter and repeated oral demands, Defendant
failed and still refused to pay the agreed amount of rentals and to
vacate the apartment;
8. On August 7, 2012, Plaintiff brought the matter before the Barangay
Authorities for conciliation but no settlement was reached (Annex
“E”);
9. By reason of failure of Defendant to vacate the premises and to pay
the unpaid rentals, Plaintiff was compelled to file this Complaint
engaging the services of counsel in the amount of Php 10,000.00.

PRAYER

WHEREFORE, premises considered, Plaintiff most respectfully prays

unto this Honorable Court that, after hearing, judgment be rendered
ordering Defendant:
 28

1. To vacate the subject premises;

2. To pay the amount of Php 8,000.00 per month as compensation for
the reasonable use of the subject premises until he finally vacates
it; and
3. To pay Plaintiff the cost of the suit.

Other reliefs, just and equitable, are likewise prayed for

Baguio City, February 7, 2013.

JUAN TAMAD
Counsel for Plaintiff
PTR No. 1128374/1-4-12/Baguio City
Roll of Attorney No.689898/1-4-12-Baguio-Benguet
MCLE Compliance No.III-002/1-10-12
Rooms 374, 2nd Floor, PNA Building,
Upper Session Road, Baguio City
TIN No. 673-111-786

Copy furnished:
ATTY. TAYLOR SWAPANG
Counsel for Defendant
Rm. 201, 2nd Floor Pilando Building
#254 Magsaysay Avenue, Baguio City

VERIFICATION AND CERTIFICATION AGAINST FORUM-SHOPPING

JURAT
 29

SAMPLE FORM 24
Complaint for ejectment with damages

Regional Trial Court

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Quezon City, Branch 33

ALIS DI-YAN COMPANY.

Plaintiff, Civil Case.2222
-versus- For: Ejectment

YOKO NGA,
Defendant
x--------------------------------------x

COMPLAINT

Plaintiff, by counsel, respectfully states that:

1. Plaintiff is a foreign corporation organized and existing under

the laws of France with business address at 111 Ocean Drive, Tuna
Compound, Quezon City; Defendant is a Filipino, of legal age, single
and currently resident of 112 Ocean Drive, Tuna Compound, Quezon
City, where he may be served with summons and other pertinent
processes.
2. Plaintiff owns that property located at 112 Ocean Drive, Tuna
Compound, Quezon City which it leased to defendant under the terms
and conditions stated in the Contract of Lease dated 1 January 2005,
 30

which contract on 31 December 2006. A copy of the contract is attached

as ANNEX A.
3. Upon expiration of the contract, plaintiff informed defendant
of its intention not to renew the lease as it would use the property for
its business expansion; plaintiff then asked defendant to vacate the
premises. A copy of plaintiff’s letter to defendant is attached as
ANNEX B.
4. Despite demand duly made and received, defendant has
refused to vacate the premises and continues to occupy the property
without plaintiff’s consent. Resort to the Barangay Conciliation system
proved unless as defendant refused to appear before the Lupong
Tagapamayapa. A Certification to File Action is attached as ANNEX C.
5. Defendant’s act of dispossession has caused plaintiff to suffer
material injury because plaintiff’s business expansion plans could not
be implemented despite the arrival of machineries specifically leased
for this purpose at the rental rate of xx per month. Defendant’s
continued occupation of the premises has also forced plaintiff to sue
and to incur expenses amounting to P50,000.00
6. WHEREFORE, plaintiff respectfully prays for judgment in its
favor by ordering defendant to vacate the property and peacefully turn
over possession to plaintiff and for defendant to pay plaintiff the
amount of xx representing rentals of on the machineries for seven (7)
months and 50,000.00 for Attorney’s fees.
Other just and equitable reliefs are also prayed for.

Quezon City, 13 April 2007

ATTICUS FINCH
Counsel for Plaintiff

Verification and Certification Against Forum Shopping

 31

Jurat

T o be continued..
 32

SAMPLE FORM 25
Answer with Counterclaim

Regional Trial Court

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Branch 33, Quezon City

ALIS DI-YAN COMPANY,

Plaintiff, Civil Case No.222
For: Ejectment

-versus-

YOKO NGA,
Defendant,
x---------------------------------x

ANSWER
(With Counterclaim)

DEFENDANT, by counsel, respectfully states that:

1. He admits the contents of paragraph 1 only insofar as his personal

circumstances but specifically denies the contents insofar as
plaintiff’s circumstances for the reason stated in the Affirmative
Defenses below.

2. He admits the contents of paragraph 2 only where it states that a

Contract of Lease was entered into but specifically denies that the
Contract reflects the true intent of the parties as explained in the
Affirmative Defenses below.
 33

3. He admits the contents of paragraph 3 only as to the fact that demand

to vacate was made but specifically denies its contents as to the truth
of the reasons for the letter for lack of knowledge sufficient to form a
reasonable belief as to its truth or falseness.

4. He specifically denies the contents of paragraphs 4 to 6 for the

reasons stated in the Affirmative Defenses below.

AFFIRMATIVE DEFENSES

5. Defendant reiterates, repleads and incorporates by reference all the

foregoing insofar as they are material and additionally submit that
the Complaint should be dismissed because:

5.1 Moral Damages amounting to One Million Pesos (Php

1,000.000.00) because his name and reputation were
besmirched by this malicious and baseless suit.
5.2 Attorney’s Fees amounting to One Hundred Thousand Pesos
(Php 100,000.00) because he was compelled to secure services
of counsel to vindicate his legal rights.

WHEREFORE, Defendant respectfully prays that judgment be rendered

in his favor by dismissing the Complaint and granting defendant’s
counterclaim by awarding defendant: a)

SAMPLE FORM 26

SAMPLE FORM 27

SAMPLE FORM 28

SAMPLE FORM 29

SAMPLE FORM 30

SAMPLE FORM 31
34